DOJ-OGR-00009547.jpg
717 KB
Extraction Summary
10
People
3
Organizations
0
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
717 KB
Summary
This legal document is a page from a court filing, likely an opinion or order, dated February 25, 2022. The court is addressing a defendant's argument for an evidentiary hearing, rejecting it by citing numerous legal precedents that establish a very high standard for post-verdict inquiries into jury conduct. The court emphasizes that motions to set aside verdicts are disfavored and that allowing such inquiries without concrete evidence could lead to negative consequences like jury harassment and tampering.
People (10)
| Name | Role | Context |
|---|---|---|
| Baker |
Party in the cited case 'Baker, 899 F.3d 123, 130'.
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| Moon |
Party in the cited case 'United States v. Moon, 718 F.2d 1210, 1234'.
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| Stewart |
Party in the cited case 'United States v. Stewart, 317 F. Supp. 2d 432, 443'.
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| Ianniello |
Party in the cited case 'United States v. Ianniello, 866 F.2d 540, 543'.
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| Maxwell | Defendant |
Mentioned as the Defendant who filed the 'Maxwell Reply'.
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| McDonough |
Referenced in the context of a 'McDonough hearing'.
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| Ventura |
Party in the cited case 'United States v. Ventura, No. 09-CR-1015 (JGK)'.
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| Tanner |
Party in the cited case 'Tanner v. United States, 483 U.S. 107, 119–20'.
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| McDonald |
Party in the cited case 'McDonald v. Pless, 238 U.S. 264, 267–68'.
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| Pless |
Party in the cited case 'McDonald v. Pless, 238 U.S. 264, 267–68'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Second Circuit | Government agency |
Cited as a court that has set legal standards and warnings regarding post-verdict inquiries.
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| S.D.N.Y. | Government agency |
Abbreviation for the Southern District of New York court, where cases like 'United States v. Stewart' and 'United Sta...
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| DOJ | Government agency |
Appears in the footer as 'DOJ-OGR-00009547', likely indicating the Department of Justice.
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Relationships (1)
The Defendant (Maxwell) is arguing against the standard being applied by the Court for an evidentiary hearing.
Key Quotes (5)
"[g]ossip and anonymous tips do not satisfy this standard."Source
— United States v. Moon
(Quoted in Baker, establishing that mere gossip is insufficient for legal action.)
DOJ-OGR-00009547.jpg
Quote #1
"[a]llegations of impropriety must be ‘concrete allegations of inappropriate conduct that constitute competent and relevant evidence.’"Source
— United States v. Ianniello
(Quoted in Baker, defining the high standard for allegations of impropriety.)
DOJ-OGR-00009547.jpg
Quote #2
"motions to set aside a jury verdict are disfavored."Source
— United States v. Ventura
(Stating the court's general position on challenging jury verdicts.)
DOJ-OGR-00009547.jpg
Quote #3
"post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts."Source
— Ianniello
(A warning from the Second Circuit about the dangers of questioning jury verdicts after the fact.)
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Quote #4
"is not held to afford a convicted defendant the opportunity ‘to conduct a fishing expedition.’"Source
— Moon
(Quoted in Stewart, explaining that an evidentiary hearing is not for speculative investigation by the defendant.)
DOJ-OGR-00009547.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,076 characters)
Case 1:20-cr-00330-PAE Document 620 Filed 02/25/22 Page 6 of 21
Baker, 899 F.3d 123, 130 (2d Cir. 2018) (cleaned up) (quoting United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983)). Mere “[g]ossip and anonymous tips do not satisfy this standard.” United States v. Stewart, 317 F. Supp. 2d 432, 443 (S.D.N.Y. 2004). Rather, “[a]llegations of impropriety must be ‘concrete allegations of inappropriate conduct that constitute competent and relevant evidence.’” Baker, 899 F.3d at 130 (quoting United States v. Ianniello, 866 F.2d 540, 543 (2d Cir. 1989)).
The Defendant argues that this is the wrong standard. Maxwell Reply, Feb. 9, 2022, at 8 n.4. But the Defendant does not identify an alternative standard. And the Second Circuit has applied precisely this standard to determine whether a district court should hold a McDonough hearing on the basis of a juror’s nondisclosure during voir dire. Stewart, 433 F.3d at 302–03. The Court is bound to apply this demanding standard.
This high standard for an evidentiary hearing intentionally raises an “exacting hurdle” for defendants because “motions to set aside a jury verdict are disfavored.” United States v. Ventura, No. 09-CR-1015 (JGK), 2014 WL 259655, at *3 (S.D.N.Y. Jan. 21, 2014). As the Second Circuit has repeatedly warned, “post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts.” Ianniello, 866 F.2d at 543; see also Tanner v. United States, 483 U.S. 107, 119–20 (1987) (citing McDonald v. Pless, 238 U.S. 264, 267–68 (1915)). And an evidentiary hearing “is not held to afford a convicted defendant the opportunity ‘to conduct a fishing expedition.’” Stewart, 433 F.3d at 306 (quoting Moon, 718 F.2d at 1234).
The Defendant argues that the considerations in Tanner and Ianniello are inapplicable to her motion because those cases “involved alleged conduct during trial and, crucially, during
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DOJ-OGR-00009547
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